PRIVACY & COOKIE POLICY

Last updated: December 5, 2019

Kwatt Swap (“us”, “we”, or “our”) operates the Kwatt Swap website (the “Service”).

KwattSwap understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.kwattswap.org (“Our Site”) and only collect and use your personal data as described in this Policy.

We will not use or share your information with anyone except as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.

Please read this Privacy & Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Privacy & Cookie Policy is deemed to occur when you press the accept button on Our pop-up. If you do not agree to Our Privacy & Cookie Policy, please stop using Our Site immediately.


1. Definitions and Interpretation

In this Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings:

    “Cookie” – means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site; means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;

    “Cookie Law” – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);

    “personal data” – means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);

    “We/Us/Our” – means KwattSwap a charity organisation registered in England. Registered and Postal address: is Arquen House, 4-6 Spicer Street, St Albans, AL3 4PQ;


2. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.


3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.


4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.

b) The right to access the personal data we hold about you. Part 9 will tell you how to do this.

c) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.

d) The right to access the personal data we hold about you. Part 14 will tell you how to do this.

e) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.

f) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 14 to find out more.

g) The right to restrict (i.e. prevent) the processing of your personal data.

h) The right to object to us using your personal data for a particular purpose or purposes.

i) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

j) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

k) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 14.


5. What Personal Data Do You Collect and How?

Subject to the following, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.

Our Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.

If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.

The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of Our Site. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.


6. How Do You Use My Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 8, below.

As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of Our Site.

We will not share any of your personal data with any third parties for any purposes, other than storage on an email and/or web hosting server.


7. How and Where Do You Store My Data?

We will only store your personal data on GDPR compliant servers. This means that it will be fully protected under the Data Protection Legislation.

We may store some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We store your data with an external third party, as detailed below, that is based outside of the EEA. The following safeguard is applied:

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Personal data security is essential to us, and to protect personal data, we take the following measures:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

  • 8. Do You Share My Personal Data?

    We will not share any of your personal data with strangers. We may contract with the following third party for hosting and data storage purposes:

  • digitalocean.com (US)
  • If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

    If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.


    9. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.


    10. How Does Our Site Use Cookies?

    Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

    By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for advertising services.

    All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:

      Strictly Necessary Cookies: A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.

      Analytics Cookies: It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.

      Functionality Cookies: Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.

      Targeting Cookies: It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests.

      Persistent Cookies: Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.

      Session Cookies: Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.

    Cookies on Our Site are not permanent and will expire as indicated in the table below.

    For more details of the personal data that We collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy section.

    For more specific details of the Cookies that We use, please refer to the table below.


    11. What Cookies Does Our Site Use?

    Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

    The analytics service(s) used by Our Site use(s) the following analytics Cookies:

    TABLE here

    Name of Cookie Strictly Necessary Purpose & Type
    __cfduid yes Used by the content network, Cloudflare, to identify trusted web traffic.
    gstatic.com no domain owned and used by Google for loading content from their Content Delivery Networks (CDN)
    _gid /_ga / _gat no GA cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information such as the number of visitors to the web, where visitors have come to the website from, IP address and pages visited. Google will not associate your IP address with other data held by Google.


    12. Consent and Control

    Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies, unless those Cookies are strictly necessary; however certain features of Our Site may not function fully or as intended.

    In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

    The links below provide instructions on how to control Cookies in all mainstream browsers:

  • Google Chrome:
  • https://support.google.com/chrome/answer/95647?hl=en-GB

  • Microsoft Internet Explorer:
  • https://support.microsoft.com/en-us/kb/278835

  • Microsoft Edge:
  • https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)

  • Safari (macOS):
  • https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB

  • Safari (iOS):
  • https://support.apple.com/en-gb/HT201265

  • Mozilla Firefox:
  • https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences

  • Android:
  • https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)

    13. Changes to this Privacy & Cookie Policy

    We may change this Privacy & Cookie Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.


    14. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

  • Email address: [email protected].
  • Telephone number: 01727 834 481.
  • Postal address: is Arquen House, 4-6 Spicer Street, St Albans, AL3 4PQ